Publication and Printing Costs are defined as follows in accordance with 2 CFR § 200.461:

• Publication costs for electronic and print media, including distribution, promotion, and general handling are allowable. If these costs are not identifiable with a particular cost objective, they should be allocated as indirect costs to all benefiting activities of the non-Federal entity. 
• Page charges for professional journal publications are allowable where: 
  • The publications report work supported by the Federal government; and
  • The charges are levied impartially on all items published by the journal, whether or not under a Federal award. 

Publication charges incurred after the period of performance of an award, but prior to the award closeout, may be charged to the sponsored project. These costs must be recorded in the award general ledger in accordance with Sponsored Projects Financial Reporting Timeline.

Sponsors normally require acknowledgement of their support in all publications disseminating project results and often have requirements on how the acknowledgement must read. This must be done at the time a manuscript/paper is submitted to ensure compliance with any sponsor requirements.

Publications and journal articles produced under Federal grant-supported project must bear an acknowledgment and disclaimer.  Agency specific guidance can be found at NIH Grants Policy Statement and NSF Other Post Award Requirements and Considerations.  

For all other sponsors, agency and award terms and conditions should be reviewed to determine whether sponsor specific language is required and incorporated in the acknowledgement. Please ensure that you understand the terms and conditions of your award so sponsor support can be acknowledged correctly in the publication.

Publication and journal acknowledgements oftentimes cite multiple funding sources, which may be internal and external to Brown. Brown must comply with the federal regulations in the Cost Accounting Standards (CAS) and the Office of Management and Budget (OMB) Uniform Guidance. Brown University has established Sponsored Cost Allocation Methodology Guidance for the allocation of costs that benefit two or more projects or activities in proportions that are not easily determined.  The following guidance should be considered in determining and documenting a reasonable allocation methodology that meets the requirements in the Uniform Guidance. 

Best Practice Guidelines:

• Department Administrators should review the publication or journal to confirm compliance with sponsor citation requirements.
• Assess the citations to determine the appropriate cost allocation:
  • One Acknowledgment - Costs benefiting a single project, expenses should be allocated and directly charged to that project.
  • Multiple Acknowledgments - Uniform Guidance (§ 200.405) stipulates that it is necessary to substantiate the proportional benefit of costs when costs benefit two or more projects.
• When two or more acknowledgements are cited on the publication, all awards must be addressed in the allocation methodology.
  • Determine and document whether acknowledged awards are: 
    • Brown University awards or awards external to Brown (i.e. collaborator awards); and
    • Brown awards are active or inactive.
  • Publications costs should only be allocated to active Brown awards and to awards recognized in the publication or journal. 
• Principal Investigators, in collaboration with Department Administrators, will determine and document the allocation methodology for active, Brown awards based on the proportional benefit received by the award(s) or some other reasonable scientific or programmatic rationale.

Recommended Documentation:

• Provide a clear, reasonable justification for the allocation. The documentation should describe how the award(s) being charged contributed to the aim of the publication. 
  • Provide a clear, reasonable justification on all acknowledged awards which are not being charged (i.e. charges may be unallowable on certain awards, the award is closed but contributed to the aim of the published research, etc.). 
  • Documentation should be complete, addressing and resolving the allocation methodology for all acknowledged awards cited in the respective publication or journal. 
  • The allocation methodology and publication should accompany the publication invoice in Workday.

Non-Compliance 

Instances of non-compliance (i.e. missing publication acknowledgment, inappropriate or incomplete allocation methodology, etc.) will result in the disallowance of the publication charge and removal from the respective grant(s) to a non-sponsored cost center account.